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The No Surprises Act: The Departments Proposed Another Increase to IDR Fee, Will it Stick?

On September 26, 2023, the Departments of Health & Human Services (HHS), Labor, and the Treasury (collectively, the Departments) jointly proposed rules (September Rule) updating the administrative fee and Certified...more

Postponement in the Massachusetts Patients First Act Penalties

On July 5, 2022, the Commonwealth of Massachusetts re-extended the implementation and enforcement date for the “Patients First Act”, sometimes referred to as the Massachusetts No Surprises Act, to January 1, 2025. As...more

No Surprises Act Challenges, Win for Providers

On Wednesday, February 23, 2022, U.S. District Court Judge Jeremy Kernodle of the Eastern District of Texas granted the Texas Medical Association’s and Adam Corley’s (the Plaintiffs) motion for summary judgment on their...more

How does the Federal No Surprises Act Impact Telemedicine Providers? Part Two

In this second installment of this blog series on the No Surprises Act interim regulations (NSA) we discuss: i) notice and consent requirements for out of network providers providing services at participating health care...more

How does the Federal No Surprises Act Impact Telemedicine Providers? Part One

In this two-part blog series, we dive into the key points for telemedicine providers in the several hundred pages of the No Surprises Act interim regulations (NSA). The good news for the telemedicine industry is that the...more

Massachusetts DPH Delays Enforcement Penalties for State Surprise Billing Law

The Massachusetts Department of Public Health (DPH) has delayed the enforcement penalties for the new notice requirements under the “Patients First Law” until July 1, 2022. This news comes as a relief to the provider...more

Government Issues No Surprises Act Interim Final Rule with Comment Period (Part II)

On September 30, 2021, the U.S. Departments of Health and Human Services (HHS), Labor and Treasury (collectively, the Departments) along with the Office of Management and Budget released “Requirements Related to Surprise...more

Federal Government Publishes an Interim Final Rule (Part 1) Implementing the No Surprises Act

Over the last several years, both the federal government and a number of state legislatures have sought to find a solution to the billing by out-of-network providers, referred to as “Out of Network Billing” (OON Billing) and...more

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